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United Kingdom Borrowers HMRC

Proskauer Rose LLP

UK Tax Round Up - June 2024

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Welcome to the June edition of the UK Tax Round Up. This month features the latest Court of Appeal decision in a trilogy of recent cases regarding the loan relationship “unallowable purpose” test, an Upper Tribunal decision...more

Cadwalader, Wickersham & Taft LLP

An option to dispose of property does not necessarily give rise to a taxable disposal

In the appeal case of Krishnamohan v HMRC [2024] UKFTT 346, the UK’s First-Tier Tribunal (“FTT”) determined that an agreement titled “Option Agreement” that was entered into to dispose of certain properties, does not, for...more

Faegre Drinker Biddle & Reath LLP

The Return of Crown Preference — Implications for Borrowers and Lenders

The first day of December witnessed an early visit from the ghost of Christmas past for the rules relating to the order of priority on insolvency. For insolvencies commenced on or after 1 December 2020, Her Majesty’s Revenue...more

K&L Gates LLP

COVID 19: UK Insolvency Reform – Crown Preference Returns From 1 December 2020

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EXECUTIVE SUMMARY - On a UK company’s insolvency, the UK tax authority (HMRC) will become a preferential creditor in respect of certain unpaid taxes (Crown Preference) with effect from 1 December 2020. Despite lobbying...more

Proskauer Rose LLP

UK Tax Round Up - June 2018

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Streaming of losses on trade succession (Leekes v. HMRC) - This case involved a taxpayer who purchased a business (the "predecessor business") and combined it with their existing business (creating the "enlarged...more

Proskauer Rose LLP

Tax Round Up - May 2017

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Budget and Finance Bill - General Election – Finance Bill (No.2) 2017 Curtailed - The Finance (No.2) Bill received Royal Assent on 27 April 2017, becoming the Finance Act 2017. However, as a result of Theresa May...more

Morrison & Foerster LLP

The Private Placements Withholding Tax Exemption

Morrison & Foerster LLP on

The Finance Act 2015 introduced an exemption from a borrower’s obligation to withhold tax from interest payments arising on qualifying private placements. It was introduced to stimulate and grow the private placements market...more

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